GenCounsel Privacy Policy

Effective Date: October 25, 2023

GenCounsel LLC (“GenCounsel” or “we”, “our”, or “us”) respects your privacy and we are committed to protecting it through our compliance with this policy.  GenCounsel operates the https://gencounsel.com website (the “Website”).  This policy applies to information we collect through the Website and in electronic messages between you and the Website.  It does not apply to information collected by us offline or through any other means, including on any other website operated by any third party; or any third party, including through any application or content (including advertising) that may link to or be accessible from the Website.

This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Website and the choices you have associated with that data.

By using the Website, you agree to the collection and use of information in accordance with this policy.  This policy may change from time to time (see Changes to This Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Definitions

Personal Data

Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Usage Data

Usage Data is data collected automatically either generated by the use of the Website or from the Website infrastructure itself (for example, the duration of a page visit).

Cookies

Cookies are small files stored on your device (computer or mobile device).

Data Controller

Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.  For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

Data Processors (or Service Providers)

Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

Data Subject (or User)

Data Subject is any living individual who is using our Website and is the subject of Personal Data.

Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Website to you.

Types of Data Collected

Personal Data

While using our Website, we may ask you to provide us with Personal Data. Personal Data may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City
• Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.

Usage Data

We may also collect Usage Data. This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Cookies Data

• We partner with Thomson Reuters in connection with this Website. Information regarding Cookies Data is included in Thomson Reuters’ privacy policy linked at the end of this policy.

Use of Data

GenCounsel uses the collected data for various purposes:

• To provide and maintain our Website
• To notify you about changes to our Website
• To allow you to participate in interactive features of our Website when you choose to do so
• To provide customer support
• To gather analysis or valuable information so that we can improve our Website
• To monitor the usage of our Website
• To detect, prevent and address technical issues
• To provide you with news, special offers and general information about services which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.

Retention of Data

GenCounsel will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

GenCounsel will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Website, or we are legally obligated to retain this data for longer periods.

Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

GenCounsel will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of Data

Business Transaction

If GenCounsel is involved in a merger, acquisition or asset sale, your Personal Data may be transferred.

Disclosure for Law Enforcement

Under certain circumstances, GenCounsel may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

GenCounsel may disclose your Personal Data in the good faith belief that such action is necessary to:

• To comply with a legal obligation
• To protect and defend the rights or property of GenCounsel
• To prevent or investigate possible wrongdoing in connection with the Website
• To protect the personal safety of users of the Website or the public
• To protect against legal liability

Purpose

GenCounsel may disclose your Personal Data fulfill the purpose for which you provide it, for any other purpose disclosed by us when you provide the information, or otherwise with your consent.

Security of Data

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained in the Website.

Our Policy on “Do Not Track” Signals under the California Online Protection Act (CalOPPA)

We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Your Data Protection Rights under the General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. GenCounsel aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.  GenCounsel’s legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

GenCounsel may process your Personal Data:

• To perform a contract with you
• Because you have given us permission to do so
• Because the processing is in our legitimate interests and it is not overridden by your rights
• To comply with the law

If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.

The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

The right to object. You have the right to object to our processing of your Personal Data.

The right of restriction. You have the right to request that we restrict the processing of your personal information.

The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.

The right to withdraw consent. You also have the right to withdraw your consent at any time where GenCounsel relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Service Providers

We may employ Servcie Providers (including Thomson Reuters) to facilitate our Website, provide the Website on our behalf, perform Website-related services or assist us in analyzing how our Website is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.  These uses may include analytics of the use of our Website, and remarketing to advertise to you after you have visited our website.  We and our third-party Service Providers may use cookies for this purpose.

Links to Other Sites

Our Website may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children’s Privacy

Our Website does not address anyone under the age of 18 (“Child”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a Child, do not provide any information to the Website.  If you are a parent or guardian and you are aware that your Child has provided us with information, please contact us. If we become aware that we have collected information from any Child without verification of parental consent, we take steps to remove that information from our servers.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Website, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us:

• By email: [email protected]
• By visiting this page on our website: https://gencounsel.com/contact-us/

We partner with Thomson Reuters, who might also collect data as part of our marketing efforts. To learn more about the Thomson Reuters privacy policy and the data that might be collected, please visit: Thomson Reuters Privacy Statement.